TE 2B Quality Assurance Surveillance Plan.pdf

70LGLY25RGLB00005

Uniform, Equipment Issue and Laundry Services FLETC, Glynco, GA

QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

1.1 INTRODUCTION

The Quality Assurance Surveillance Plan (QASP) provides a systematic method to evaluate the services the Contractor is required to furnish. It does not detail how the Contractor accomplishes the work. The plan uses a combination of Office of Federal Procurement Policy (OFPP) surveillance methods to adequately assure the Government of the Contractor's performance, while keeping the cost of surveillance within the requirements of Office of Management and Budget (OMB) Circular A-76.

This QASP is based on the premise that the Contractor, and not the Government, is responsible for management and quality control actions to meet the terms of the contract. The Acceptable Quality Level (AQL's) recognizes that the Contractor is not a perfect manager, and that unforeseen and uncontrollable problems do occur. Good management and use of an adequate quality control plan will allow the Contractor to operate within the allowable AQLs. The Contracting Officer’s Representatives (COR) Inspector/Monitor surveillance methods are to be objective, fair and consistent in evaluating Contractor performance against the contract standards.

The Government's primary quality assurance procedures are based upon random sampling of the recurring critical services of the contract, using the concepts of OFPP. Portions of the statement of work not covered by the Performance Requirements Summary (PRS) in the contract will be reviewed periodically (i.e., daily, weekly, monthly, quarterly) in accordance with FAR clause 52.246-4, Inspection of Services-Fixed Price. Student Notification System is an integral part of the Government surveillance plan. Customer complaints can and will highlight service problems.

When random sampling indicates unsatisfactory performance, documented customer complaints can be used to support invoice reductions.

1.2 SURVIELANCE TERMS

a. Acceptable Quality Level (AQL) - The allowable margin from a standard that can occur before the Government will reject the specific service. The number of defects in a lot ( or the maximum percent defective in a lot) that, for purposes of sampling, may occur before the Government will affect the price computation system in accordance with the Performance Requirements Summary and the INSPECTION OF SERVICES Clause.

An AQL does not allow the Contractor to knowingly offer defective service, but implies that the Government recognizes that defective performance sometimes happens unintentionally. As long as the percent of defective performance does not exceed the AQL, the service will not be rejected by the Government.

The Contractor, however, must re-perform the defective service when possible. The AQL limits reduced payment to circumstances in which defective performance results in a measurable reduction in the value of services rendered.

b. Acceptable Sampling - A form of sampling used to determine a course of action. A procedure that gives a specified risk of accepting lots of given quality.

b. Contract Discrepancy Report (CDR) - Form initiated by the COR when any service is judged unsatisfactory. A formal, written documentation of Contractor non-conformance or lack of performance of contract work.

c. COR/Inspector Evaluation Schedule - The work sheet that indicates what inspections are to be performed on which days of the week/month. It is determined by the COR/inspector before the start of each inspection period and provided to the CO only. It is never revealed to the Contractor.

d. Contractor - Both the prime Contractor and any subcontractors. The Contractor shall be responsible for all compliance with the provisions of this contract, including those services provided by the Contractor's subcontractors.

e. Contractor Representative - A supervisor or manager assigned in accordance with

CONTRACTOR PROJECT/CONTRACT MANAGER Clause.

f. Cure Notice - A dated notice stating the Contractor's failure to comply with the specifications and a deadline to comply with the stated specification.

g. Customer Complaints - One of the criteria used to monitor the Contractor's performance.

h. Defective Service - A unit of service which contains one or more defects or nonconformance with specified requirements.

i. Delivery Order - A formal order for services placed against this contract and signed by the CO.

j. Facility - A separate individual building, structure, or other item of real property improvement, each item of which is subject to separate reporting and recording.

k. Lot - The total number of product or service outputs in a surveillance period from which a sample is to be drawn and inspected to determine performance in accordance with the standard, as defined in the AQL column of the Performance Requirements Summary.

l. Lot Size – The number of service outputs in a lot.

m. Percent of Sample Found Defective - Determined by dividing the number of defects by the sample size when the reject number has been equaled or exceeded. The resulting number is used to make an equitable reduction to the contract price for non-performance by the Contractor.

n. Performance Requirements Summary (PRS) - A condensed listing of the tasks, standards, AQLs, surveillance methods, and relative value of the services or products required by the PWS. The PRS identifies the key service outputs of the contract that will be evaluated by the Government to assure contract performance standards are met by the Contractor.

o. Quality Assurance (QA) - The actions taken by the Government to assure services meet the requirements of the Performance Work Statement. The procedures used by the Government to inspect the Contractor's Quality Control program and provide control over the quality of services received to ensure satisfactory performance.

p. Quality Assurance Surveillance Plan (QASP) - An organized written document prepared and used by the Government for Quality Assurance surveillance of the Contractor's performance. The document contains the Government's specific methods, sampling guides, checklists, decision tables, etc. used in determining whether the Contractor provided service meets quantity, quality, timeliness, effectiveness, and/or total cost standards.

q. Quality Control (OC) - The Contractor's inspection system which covers all the services to be performed under this contract (i.e., his method for identifying deficiencies in the quality of services performed before the level of performance becomes unacceptable).

The actions that a Contractor takes to control the production of products or services so that they will meet the requirements stated in the contract.

r. Random Sampling - A sampling method in which each service output in a lot has an equal chance of being selected for inspection. By this method of surveillance, a few individual items, selected at random, are examined, and a conclusion drawn about the entire lot.

s. Receiving Report - The receiving document, initiated by the Contractor or Contractor employee(s), indicating that services have been performed.

t. Recurring Services - Those services which are identified in this contract as being performed on a recurring, periodic, or standing basis.

u. Rework-Work - which, in the judgment of the CO or the COR, is not of an acceptable quality level, and must be corrected or re-performed at no additional cost to the Government.

v. Sample - One or more service outputs drawn from a lot. The number of outputs in the sample is the sample size.

w. Sampling - The generic term for various methods of selecting service outputs to be inspected under a Quality Assurance System.

x. Sampling Guide - The part of the surveillance plan which contains all the information needed to perform a random sample.

y. Using Activity - That agency/division requesting services that would be responsible for payment.

2. COR/INSPECTOR EVALUATION SCHEDULE

The COR will develop a monthly surveillance schedule based on this surveillance plan's requirements. This monthly schedule shows where and what the COR/Inspector is monitoring at all times. The monthly schedule will be completed not later than the last workday of the preceding month. Copies of the schedule shall be sent to the CO. After it is filled in, the schedule shall be marked "FOR OFFICIAL USE ONLY" and must not be shown to the Contractor.

Contract surveillance must cover regular business hours, Monday through Friday 8:00 am to 5:00

pm. Random observations are scheduled when services are performed. Select the areas and times for random sampling using the procedures in the sampling guides. Annotate the selected inspection items/times on the schedule. When the sampling concept does not allow for specific selection of inspection items/times during the preceding month, show on the schedule the date the random sample selection will be accomplished.

Program any periodic surveillance into the schedule so as not to interfere with the sampling requirements.

Changes to the monthly surveillance schedule will be posted weekly with copies sent to the CO and will include documentation regarding the reasons for the changes.

3 ACTUAL SURVEILLANCE

Doing surveillance means using the surveillance plan called for in the bi-weekly schedule.

Actual surveillance should be comparable to the bi-weekly schedule. It is essential that the exact number of inspections in a random sample be accomplished. It is also essential that the exact number of periodic checklist inspections be done for an effective quality assurance system. A complete audit trail must exist from the bi-weekly schedule, to observing the COR/Inspector perform sampling, to completion of the Contract Compliance Inspection sheet.

If less than the required number of inspections are made or inspections are made outside the randomly selected sample, the ability to project from random sample results to lot results is destroyed. If this should occur, consider the missed inspections acceptable. This will increase the Government's risk of accepting a defective lot.

NOTE: If random sampling is the method of surveillance covering a seven-day service and surveillance is limited to five days, consider splitting the service into two separate PRS line items: the weekday service covered by random sampling and the weekend service covered by customer complaint.

In either case, only those defects recorded by the COR during scheduled surveillance may be used to determine the level of contract performance. Errors found in services not scheduled for observation should be brought to the Contractor’s attention but not used to count as a defect for determining if the AQL has been met.

It may be necessary to overdraw the random sample by 10 percent or more to create a pool of randomly selected potential replacement samples since some original samples selected may not be surveilled, or additional samples may be needed due to changes in the lot size. If replacement samples are used they must be used in the order drawn for the time remaining in the month.

4 RANDOM SAMPLING SURVEILLANCE

When random sampling is the method of surveillance, record the results of the inspection. These documents then become the official record of the Contractor's performance.

For areas surveilled by sampling, criteria are derived from the lot size (number of times an event takes place in a month), AQL and Sample Size Chart, and Single Sampling for Normal Inspections for each contract requirement. When the number of defects in the Contractor's performance discovered by the COR/Inspector exceeds the allowable number of defects, the Contractor's performance will be considered unsatisfactory. When a surveillance observation results in an unacceptable rating recorded on the front of the checklist, the specific reason for the unacceptable performance must be recorded on the back of the tally checklist.

The Contractor is required to immediately correct, if possible, all defects detected during surveillance by the COR. Any defects not corrected by the Contractor within a one (1) hour timeframe shall count as defects during surveillance.

During the month, the COR may receive customer complaints about the quality of the service or may observe unacceptable performance by the Contractor other than during a sample observation. These complaints and observations will be noted and should reinforce the accuracy of the sample results, but they will not be counted as a defective. Only defects discovered during sample observations will be counted when sampling is the method of surveillance. Only one surveillance method may be used during an inspection period to cause less than maximum payment for the listed service.

If the number of defects recorded on the tally checklist exceeds the AQL, the COR will determine the possible cause of this unacceptable performance. If any Government action or lack of action caused unacceptable performance, these defects shall not be counted. Any determination as to the reasons for the defects will not be shared with the Contractor as the

Contractor must manage the corrective actions as deemed necessary to deliver the contract requirements.

When the Government has not caused the Contractor to perform in an unsatisfactory manner, the COR prepares a letter to the responsible organization, requesting corrective action be taken. The COR sends this letter to the organization through the CO.

5 INFORM CONTRACT MANAGER

As a rule, the COR must always contact the Contractor's manager or on-site representative and inform the manager of what was wrong. Allow the Contractor to correct the problem, if possible.

There is no need to do this in writing. However, when possible, have the manager initial the entry on the tally or surveillance activity checklist. When the Contractor does not initial the checklist, the COR must note on the back of the checklist where the defect is recorded, the time and method of notification, and the COR's initials.

6 CONTRACT DISCREPANCY REPORT (CDR)

If the performance in any area is unsatisfactory, the Contractor is required to respond to a Contract Discrepancy Report (CDR). Normally CDRs are issued at the end of the month. But, if the failure is serious enough, the CDR will be issued at the time of the unsatisfactory performance.

Not later than the third workday of the month following the surveillance, the COR initiates the CDR and sends it, with the checklist recording the unacceptable performance, to the Contracting Officer (CO). The COR checks the Contractor's performance and documents any non-compliance. Only the CO may take final action against the Contractor for unsatisfactory performance. The CO will evaluate the CDR and, if appropriate, sign and send it to the Contractor.

The Contractor shall reply in writing, giving the reason(s) for unsatisfactory performance, the corrective action(s) to be taken to prevent recurrence, and the completion date of the corrective action(s).

When completed and signed, the CDR, along with the surveillance checklist and any other appropriate forms, reports, etc., becomes the documentation supporting payment, nonpayment, or other necessary action.

When a CDR is issued for a specific service, the CO reduces the month’s payment by an amount up to the percentages indicated in the Performance Requirements Summary. Since the Contractor is required (under the INSPECTION OF SERVICES Clause) to maintain an effective inspection system, the Contractor shall be presumed to have actual knowledge of work not performed, and written notice will not be a prerequisite to withholding payment for unperformed services.

Payment reductions will not be delayed until the Contractor responds to the CDR.

If the Contractor does not achieve satisfactory performance in the specific service by the end of the next month, the CO issues another CDR and reduces payment to the Contractor by the appropriate amount. When the Contractor's performance is unsatisfactory and a formal action is indicated, the COR and the CO meet to determine what action is appropriate for the specific circumstances.

If a decision is reached not to take a monetary reduction, the reasons are documented. The CO must indicate agreement with the decision by signing the CDR or other decision documentation.

7 OTHER SURVEILLANCE METHODS

For areas not surveilled by sampling, the Government reserves the right to use the Inspection of Services Clause in conjunction with the Statement of Work.

There are some contractual requirements of a general nature that do not properly fit under the random sampling concept. These are surveilled by customer complaint or by checklists (daily, monthly, etc.). Services surveilled by methods other than sampling shall have the surveillance documented on the appropriate surveillance activity checklist. The recordings of defects or unacceptable services are the same as described above.

8 SURVEILLANCE BY CUSTOMER COMPLAINT

Certain contract requirements can best be monitored by the individual or activity receiving the, service, or customer complaints may be used to supplement other surveillance information.

Each customer complaint is submitted via email, phone call, verbal communication, Student Notification System, or Student Critique to the COR.

When a complaint is received, the COR will investigate, validate the complaint, and notify the Contractor of the defect. The COR will maintain a record of the complaints and findings. At the end of the month all validated complaints will be counted to determine if performance is satisfactory or unsatisfactory based on the criteria in the AQL column of the Performance Requirements Summary and will be taken into consideration for entries into Contractor Performance Assessment Reporting System (CPARS) at the end of the basic and each option year. Copies will also be provided to the CO upon request.

9 REDUCED INSPECTIONS

When the Contractor's quality control plan works, good performance results. If the COR's surveillance shows consistently good performance, the amount of surveillance can be decreased.

Inspection can be reduced when the following conditions have been met for any required service:

a. The preceding four lots (that is, the last four months) have been acceptable.

b. The number of defects in each of the preceding four lots is 50 percent or less of the acceptance number.

For example, with an AQL of 6.5 percent and a sample size of 32, the acceptance number is five (5). If two or less defects were found in each of the last four lots, reduced inspection could be used.

c. The normal sample size was used in the last inspection.

d. The CO approves of reduced inspections.

Reduced inspections decrease the sample size. In addition, the acceptance and rejection numbers change.

Inspection will be returned to normal the next month under the following conditions:

a. When the number of defects exceeds the acceptance number under the reduced sampling or,

b. The appropriate Government personnel and the CO deem it necessary to return to normal inspection.

If during the first month of the return to normal inspection the number of defects found is again 50 percent or less of the acceptance level, a return to reduced inspection may be done the next month. If the number of defects exceeds 50 percent, then normal sampling must be accomplished until four consecutive months of 50 percent or less of acceptance level defects are found.

10 PAYMENT REDUCTIONS FOR UNSATISFACTORY PERFORMANCE

Each month, Contractor performance will be compared to contract standards and acceptable quality levels using the performance requirements summary. Through the Inspection of Services clause, the Government can deduct from a Contractor's payment an amount equal to the services not provided.

If performance of required service is unsatisfactory, and the unsatisfactory performance is clearly the fault of the Contractor, an amount of money up to the percentage stated in column eight of the Performance Requirements Summary.

In the example, below the percentage cost of quality completed work is 10 percent. This is multiplied by $100,000 to obtain the maximum amount of pay.

As an example, suppose the Delivery Order showed the monthly contract price for services as shown below. The percentage cost of the required service is found by looking at the Performance Requirements Summary. In the example below the percentage cost of quality completed work is 10 percent. This is multiplied by $100,000 to obtain the maximum amount of pay.

If completed work was unsatisfactory during the month (that is, did not meet performance values), and the percent of the sample found good was 80 percent, $8,000 would be paid in lieu of the $10,000 payment normally due the Contractor.

The payment amount is reduced because the Contractor failed to provide reliable, uniform services within the assigned performance requirements. Although some completed work may have met the standard during the month, the acceptable quality level was not met and at least 20 percent of the observations were defective. Hence, the total quality performance requirement has not been achieved; as a consequence, the service received is unsatisfactory.

Example of unsatisfactory performance sampling deduction:

If; Quality of completed work is unsatisfactory (exceeded AQL of 6.5 percent) and; Contract price is $100,000 for this month and; The proportion of required service to total contract price is 10 percent Sample size is 50 and: Sample size is 50

Then: Payment for quality-completed work is:

Contract price $100,000 x Payment percentage .10

$ 10,000 .80 x Percent of sample good Payment for this service $8,000.00

For areas not surveilled by sampling the percentage of the monthly contract price indicated in the eighth column of the Performance Requirements Summary will be reduced as above, except the defects are divided by the total lot, which is described in the sixth column.

Example:

If: Contractor personnel in violation of safety requirements (zero defects allowed) and; The reduction for this activity is 1 percent and; The lot size is 50 employees and; The number of defects is 10 then; Reduction from the current month’s invoice is:

Contract price: $10,000 x Deduct percentage .01 $ 100

X Percentage of lot defective .20 Reduction $ 20

When areas are not surveilled by sampling, a defect will not be counted when the service can be re-accomplished, but the Contractor may be liable for the Government's reinspection costs.

For these areas that are surveilled on a less than monthly basis, the deduction will be taken from the month's invoice when that area was reviewed and found unsatisfactory.

In the case of non-performed work, the Government shall deduct from the. Contractor's invoice all billings

The taking of deductions shall not be deemed to waive or limit any right of the Government under the DEFAULT & TERMINATION CLAUSES or the INSPECTION OF SERVICES clause. Depending on the Contractor's overall performance (for example, repeated instances of nonperformance or unsatisfactory performance), the Government may issue a Cure Notice, a Show Cause letter, or terminate the contract.

11 INSPECTING

The Government will evaluate the Contractor’s performance under this contract in accordance with the QASP. This plan is primarily focused on what the Government must do to ensure that the Contractor has performed in accordance with the performance standards. The COR is required to ascertain whether the services provided by the Contractor are at an acceptable level and in conformance with the terms and conditions of this contract. After each inspection, the Contractor will be advised of any unsatisfactory condition(s) for which they are responsible. The Government’s QASP is not a substitute for quality control by the Contractor. The COR will conduct surveillance on the implementation and effectiveness of the Contractor’s Quality Control Plan (QCP). Government failure to inspect and accept or reject the supplies or services shall not relieve the Contractor from responsibility, nor impose liability on the Government, for nonconforming supplies or services.

12 NONCONFORMING SERVICES

The Government will inspect the services required herein in accordance with FAR

Clause 52.212-4 Contract Terms and Conditions – Commercial Items. The Government reserves the right to inspect or test any supplies or services that have been tendered for acceptance. The Government may require repair or replacement of nonconforming supplies or reperformance of nonconforming services at no increase in contract price. If repair/replacement or reperformance will not correct the defects or is not possible, the Government may seek an equitable price reduction or adequate consideration for acceptance of nonconforming supplies or services. The Government may reduce the Contractor’s invoice or otherwise withhold payment for any individual item of nonconforming service observed as specified in accordance with the PRS. If the Contractor does not provide services that conform to the terms and conditions of this contract, and cannot be corrected by re-performance, the contract cost may be reduced to reflect the reduced value of the services performed.

13 UNSATISFACTORY PERFORMANCE OR ACCEPTANCE

Unsatisfactory performance or acceptance is determined by the Government. The

Government has the right either to reject or to require correction of nonconforming supplies and unacceptable services based on risk to the Government and/or success of the contract. Unsatisfactory is defined as, but not limited to, repeated failure of a performance standard, significant failure of one performance standard, risk to safety and health, late deliverables, nonconforming supplies, valid customer’s complaints, and damaging public trust.

14 PERFORMANCE INFORMATION/DOCUMENTATION

In addition to Inspection documentation on specific tasks required by the Contractor, the following general aspects of contract performance will also be documented as Contractor performance information in accordance with FAR 42.15: Contractor Performance Information. The Contractor’s record of conforming to contract requirements and to standards of good workmanship; the Contractor’s record of forecasting and controlling costs; the Contractor’s adherence to contract schedules, including the administrative aspects of contract performance; the Contractor’s history of reasonable and cooperative behavior and commitment to customer satisfaction; and generally, the Contractor’s business-like concern for the interest of the customer. This information may be shared with other Government Agencies and used for evaluation purposes for future contract award consideration.

15 GOVERNMENT PERFORMANCE REPORTS

The Government may elect to use informal or formal reports to notify the Contractor of contract deficiencies based on the level of concern as defined by the Government.

The Government may use emails, letter of concerns, or CDRs. All performance reports will be used to rate performance evaluations in the Contractor Performance Assessment Reporting System (CPARS) when required or when requested by other contracting agencies for the purpose of evaluating past performance.

16 REPORTING OF CONTRACT PERFORMANCE

The Government will provide performance evaluations when required in the

Contractor Performance Assessment Reporting System (CPARS) to create and measure the quality and timely reporting of performance information. The Government will report any termination action or concern in SAM.gov under “Other

Responsibility and Integrity Information” for purposes of documenting past performance.

17 CURE NOTICE/SHOW CAUSE

The Government may issue a cure notice or show cause letter IWA FAR 12.403 as determined by the Government. FAR Clause 52.212-4(l) and (m) provides the Government rights to execute terminations as a result of, but not limited to, unsatisfactory performance, misconduct, violations of federal, state, and local laws, risk of performance failure, or health and safety concerns.

18 CONTRACTING OFFICER’S REPRESENTATIVE (COR)

The COR monitors all technical aspects of the contract and assists in contract administration. The COR is authorized to perform the following functions: Assures that the Contractor performs the technical requirements of the contract; performs inspections necessary in connection with contract performance; maintains written and oral communications with the Contractor concerning technical aspects of the contract;

issues written interpretations of technical requirements; monitors Contractor's performance and notifies both the Contracting Officer and Contractor of any deficiencies; coordinates availability of government furnished property; and provides site entry of Contractor personnel.

The COR is not authorized to change any of the terms and conditions of the contract.

19 REVISIONS TO QASP

Revisions to this surveillance plan are the joint responsibility of the COR and the CO.